A station in repeater operation, operating in conjunction with one or more stations in auxiliary operation relaying radio signals received at other locations to stations in repeater operation, may use input frequencies not available for repeater operation, provided the input frequencies to the stations in auxiliary operation are in frequency bands authorized for repeater operation. -- Federal Register, Vol. 42, page 2091 (1977).

I wrote that regulation. I am not proud that I wrote it. Even now, 3 1/2 years after the regulation was published in the Federal Register, it still embarrasses me that I permitted such a regulation to go out with my name on it. And it embarrasses me that the regulation's shortcomings were discussed, apparently in some detail, at a closed meeting of the Federal Communications Commission, my former employer. But most of all, it embarrasses me that the editors of The Washington Star selected "my" regulation (as I have come to think of it) for publication in The Star's "Gobbledygook" column, which each day highlights egregious examples of the product for which Washington is so well, and so justifiably, known.

Contrary to what you may have been led to believe, federal employees do not consider it an honor to have their handiwork publicly ridiculed. I know that I didn't; and when, three weeks later, President Carter promised, in one of his first major addresses to the nation, that federal regulations would be "written in plain English for a change," my humiliation knew no bounds. For all I knew, Carter's speech writers (or Carter himself!) had spotted my regulation and decided that something had to be done -- immediately. Hence, the president's plain-English exhortation.

Time and experience have allowed me to take a more detached view of federal gobbledygook, in general, and my contribution to it, in particular. The regulation I wrote in 1977 is really little worse than much of the flapdoodle that spews forth each day from agencies all over town. Those who read the Federal Register as part of their work see dozens of equally (well, almost equally) bad examples every week. My regulation was merely the latest in a continuing series.

Fortunately for me, my personal experiment in gobbledygook effectively ended with that one horrendous regulation. After a period of extensive reeducation at the hands of several gifted and ruthless fanatics, I emerged a new man, a maverick bureaucrat with a hatred of gobbledygook, committed to plain English in government at all cost. Incredibly, I soon found myself doing the impossible: writing regulations so that all but the functionally illiterate could understand them. With my wife, I rewrote the rules for CB radio operators into language most any good buddy could get a handle on; and in so doing, I concluded that it is possible, though not terribly easy, for a federal agency to speak plainly.

Others have made the same discovery. Several federal agencies have made serious, and successful, efforts to write regulations so the non-bureaucrats without Washington connections can understand and comply with them. Former HEW secretary Joseph Califano, for example, launched "Operation Common Sense" to review all of his department's regulations, to get rid of the obsolete rules and to rewrite the remainder. The FCC recently released new radio regulations for America's 400,000 recreational boaters, revised for readers with 8th grade educations. President Carter even issued an executive order in 1978 requiring agencies of the executive branch to issue regulations only upon a finding that the regulations are comprehensible.

Considering the mind-boggling dimensions of the problem (there were 87,681 pages of federal regulations in existence at the end of 1979), progress toward making plain English the language of the federal government has been reasonably good, but it has been uneven. This is so, I am convinced, not because of a lack of commitment on the part of the administration; nor is it because Washington bureaucrats are uncaring, insensitive or inept: Carter has consistently advocated simpler federal regulations, and most government employees are, in fact, reasonably competent and dedicated guardians of the public trust. Rather, much of the gobbledygook can be traced directly to the average bureaucrat's understandable desire to make life as easy as possible by using language with which he or she is comfortable and familiar.

Those of us who live and work in Washington have our own patois, our own sort of bureaucratic cant. It is easy to use, and we use it everyday. Some of us even love it. This is fine, I guess, as long as the only people with whom we attempt to communicate speak governmentese as fluently as do we. Bureaucrats, however, tend quickly to forget that 99 percent of the people don't speak governmentese, and that the average American could probably not distinguish between an ANPRM, an EIS and an RFP if his or her life depended upon it.

And that, I think, is the core of the problem: bureaucrats writing for bureaucrats and not for the 220 million other Americans who support the government with their taxes. Bureaucrats fail to recognize that the bulk of their audience is composed not of GS15 program managers, but of common folk who want to be told simply and accurately what their government expects of them.

The federal government, unlike the private sector, has a special responsibility to communicate in a manner the public can understand, and it is a responsibility the government is, with some notable exceptions, not fulfilling. r

And what of my infamous regulation? It is still on the books albeit in a slightly more palatable form (Code of Federal Regulations, Volume 47, Section 97.86(b)). Maybe one of these days I'll figure out what it means.